Latest

Oliver Treidler, CEO of TP&C GmbH, Berlin, comments on a December study published by the Transfer Pricing Economists for Development (TPED) that presents a new framework for selecting and adjusting foreign comparables . . .

Africa

EU blacklist: Cayman Islands added with other three jurisdictions

Davide Anghileri, a researcher at the University of Lausanne, writes that during today’s meeting, the EU Council added four countries to the EU list of non-cooperative jurisdictions for tax purposes and removed 16 countries from the gray list . . .

Digital Economy

Spanish government approves digital services tax targeting large multinationals

Dr. Patricia Lampreave, a professor at the Instituto de Estudios Busatiles, Madrid, discusses a bill for a digital service tax approved today by the Spanish government . . .

The final OECD transfer pricing guidelines for financial transactions: what has changed?

Casimir Leuridan and Melanie Beirens of Zanders, Belgium, analyze the long-awaited OECD transfer pricing guidance on financial transactions, released February 11 . . .

Americas

Impact of global tax reform effort remains unclear, senior congressional staff members say

It is unknown whether the proposed update the international system for taxing multinationals, advanced by the OECD, will benefit or harm US interests, senior staff to Congress’ tax-writing committees said at Tax Council Policy Institue conference, held in Washington DC . . .

Europe

Spain to scrutinize taxpayers’ transfer pricing positions

Pilar Barriguete and Edland Graci, Duff & Phelps, Spain, discuss new Spanish guidance which describes the international tax and transfer pricing issues that the tax authorities will focus their enforcement efforts upon in 2020 . . .

Digital Economy

OECD impact analysis shows that proposed digital tax reform won’t generate meaningful tax revenue, particularly for developing countries, NGO says: ICRICT→

Americas

US corrects date in final regs on transfers of property by US persons to partnerships with related foreign partners: US Treasury→

Digital Economy

OECD Secretariat report summarizes international tax issues for G20 finance ministers meeting with focus on digitalization, tax transparency, BEPS, capacity building: OECD→

Zuckerberg to tell German conference he supports OECD-led tax reform effort depsite likelihood Facebook will pay more tax: BBC News→

February 14, 2020

Digital Economy

Global tax rewrite could cost multinationals USD 100 billion annually, OECD says

February 13, 2020

Global corporate income tax due from multinational groups could increase by up to 4 percent or by about USD 100 billion annually if tax reforms currently being considered by 130+ countries are adopted, OECD officials said today during a presentation . . .

Asia-Pacific

India’s cabinet approves protocol to treaty with Sri Lanka that includes BEPS minimum standards: Indus Dictum→

February 12, 2020

Africa

First look: OECD publishes transfer pricing guidance on financial transactions

The OECD today published its long-awaited transfer pricing guidance on financial transactions, notes Melanie Beirens, Senior Consultant, Zanders, Belgium . . .

Europe

Sweden’s tax agency rejects Puma’s transfer pricing position, concludes risk borne elsewhere

Erik Koponen and Madeleine Thörning, transfer pricing specialists at Thorning Koponen Consulting, Sweden, discuss a recent Swedish tax agency decision rejecting a Puma subsidiary’s transfer pricing position following the approach to risk taken in the OECD transfer pricing guidelines . . .

Europe

EU court assesses legality of Netherlands’ denial of German UCITS’s dividend withholding tax refund

Jian-Cheng Ku and Tim Mulder of DLA Piper Nederland N.V., Amsterdam, analyze the European Court of Justice’s January 30 decision in the Köln-Aktienfonds Deka case concerning the legality of the Netherlands’ refusal to grant a German investment fund a dividend withholding tax refund . . .

Asia-Pacific

Korea expands R&D tax credit, other technology tax incentives

Unghwan Rap Choi, Esq., Ph.D., Partner and International Tax Leader at CKP, LLP, Irvine, California, discusses new Korean government tax incentives offered for research and development . . .

Americas

Altera appeals its loss in transfer pricing/stock-based compensation dispute to Supreme Court: Aysha Bagchi / BloombergTax→

Americas

IRS to argue this week in US Tax Court that Facebook owes an additional $9 billion taxes because it undervalued IP: Richard Rubin / Wall Street Journal→

February 10, 2020

Asia-Pacific

Turkey releases draft guidance to implement 7.5 percent digital services tax: KPMG→

February 10, 2020

Africa

Zimbabwe backdates tax holiday for Huawei Technologies

February 10, 2020

Nyasha Nigel Machiri of Baker Tilly Chartered Accountants, Zimbabwe, discusses a tax holiday granted to Huawei Technologies Co., Ltd., by the government of Zimbabwe . . .

Inclusive Framework on BEPS

Country-by-country GLoBE with 10% rate increases MNE tax by 14%, blended rule increases taxes 4%, authors conclude: Sarah Clifford, Michael P. Devereux, & Martin Simmler / University of Oxford, Said Business School→

February 9, 2020

Countries launch review of country-by-country reporting framework for multinational groups

February 9, 2020

The Inclusive Framework on BEPS, an OECD-led group of 137 countries working together on

Europe

Switzerland tax officials update intercompany loan interest rates

February 7, 2020

Elisa Kaminsky of BaseFirma, Miami, writes that Switzerland tax authorities recently issued updated safe harbor interest rates for intercompany loans for a variety of scenarios . . .

Asia-Pacific

Australian tax agency reveals plan to scrutinize non-arm’s length arrangements involving intangible assets

David Lewis, Managing Director of Duff & Phelps Australia Pty Ltd., Melbourne, discusses Australian Taxation Office (ATO) transfer pricing guidance issued January 22 which provides examples of arrangements involving intangibles that the agency considers to not be arm’s length . . .

Asia-Pacific

Indonesia plans corporate rate cut, 10 percent VAT on foreign internet company sales: Pedro Gonçalves / International Investment→

Asia-Pacific

Cisco pays New Zealand NZ 4.6m (~USD 3m) additional tax for transfer pricing compensating adjustment: Tom Pullar-Strecker / Stuff.co.nz→

Digital Economy

UK Labor MP Dame Margaret Hodge accuses Nexflix of tax avoidance: BBC News→

Africa

African tax administrators respond to Inclusive Framework meeting

The African Tax Administration Forum (ATAF), an organization of revenue authorities . . .

Europe

Ireland updates tax manual on dividend withholding, mandatory disclosure, “main purpose test”